OPINION
Opinion by CATHERINE STONE, Justice.
This is an appeal from a judgment in favor of appellee, Webb County Appraisal District, in which the trial court determined that two mobile oil drilling rigs owned by appellants, Patterson-UTI Drilling LP, LLLP, Patterson UTI Drilling (South) LP, LLP, and UTI Drilling LP (collectively "Patterson Drilling"), are subject to taxation in Webb County, Texas for the 2002 tax year. We reverse the trial court's judgment...
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